Pacific Coast Federation of Fishermen's Associations
The Pacific Coast Federation of Fishermen's Associations served a Notice wherein it states that is a customer because it will participate in the proceeding as a "representative who has been authorized by a group of customers," the second form of customer described in §1802(b).1 However, the Fishermen's Associations did not identify in its Notice the customer or customers that authorized it to represent them. (See D.98-04-059, mimeo. p. 30.)
The Fishermen's Associations states that it is an organization dedicated among other things to minimizing the environmental and economic costs of generating hydroelectricity on California Rivers. Therefore, it may qualify as a customer under the third definition described in §1802(b). Specifically, as a representative of a group or organization authorized to represent residential customers pursuant to its Articles of Incorporation or Bylaws. If the Fishermen's Associations is asserting that it meets the definition of customer through this means, it must provide a copy of its Articles or Bylaws and argue how the document demonstrates that it meets the definition. If either of those documents has been previously filed, the Fishermen's Associations needs only to refer to where the document is on file, providing proceeding number and filing date.
In the event the Fishermen's Associations asserts it is a customer because it will participate in the proceeding as a "representative who has been authorized by a group of customers," its showing of significant financial hardship needs to be amended. The amendment should include one of two things: either, argument on why the comparison test is the standard it must meet, or it should provide the financial information of the customers who authorized Fishermen's Associations to represent them so that the cannot-afford-to-pay standard may be applied. (See D.98-04-059, mimeo. pp. 34-37.)
1 I note that although the Notice was served in this proceeding and captioned under this proceeding, the Fishermen's Associations also states that it is giving notice of intent to claim compensation in the "SCE asset valuation proceedings." However, its concluding paragraph only asks for a finding of eligibility in this proceeding. In the event the Fishermen's Associations intends to request compensation in the "SCE asset valuation proceeding" it must file and serve a separate notice in that proceeding.
